Review of the
Child Support Agency’s
Complaint Service











Report under section 35A of the Ombudsman Act 1976
July 2001

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Table of Contents


1.
Executive Summary........................................................................................ 1
Purpose of the Review.................................................................................... 1
Methodology ................................................................................................... 1
Conclusions about client awareness .............................................................. 2
Conclusions from the case review process..................................................... 2
Factors contributing to the outcome ............................................................... 4
Conclusion ...................................................................................................... 4
Recommendations.......................................................................................... 4
2.
Purpose of the review ..................................................................................... 7
3.
Background to the review ............................................................................... 8
4.
Background to Complaints Service............................................................... 10
4.1
Introduction of Complaints Service...................................................... 10
4.2
The Three–Step complaints process................................................... 10
4.3
Structure of the Complaints Service.................................................... 11
4.4
Current status of the Complaints Service ............................................ 11
4.5
Internal CSA evaluation of the Complaints Service............................. 11
4.6
ANAO review of CSA Complaints Service........................................... 12
5.
Methodology........................................................................................ 13
5.1
Client Awareness of Complaints Service............................................. 13
5.2
Case Reviews ..................................................................................... 13
6.
Conclusions about client awareness ............................................................ 17
6.1
Conclusions from the Ombudsman Client Awareness Surveys .......... 17
6.2
Conclusions from the review of CSA information ................................ 18
6.3
Strategies to enhance awareness ....................................................... 20
7.
Conclusions from the case review process................................................... 22
7.1
Conclusions from the cases reviewed ................................................. 22
7.2
Areas of strength and areas needing improvement ............................ 33
8.
Factors contributing to the high ratings for the CSA’s Complaints Service... 37
9.
Conclusion .................................................................................................... 39
*Criteria used in Case Reviews to assess complaint handling.............................. 40
*Copy of Checklist................................................................................................. 41
*Detail on selection of the case review sample ..................................................... 42

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1. Executive
Summary
Purpose of the Review
My office has adopted a policy of ‘decline and refer’ for agencies that have a
viable internal complaints service, on the basis that it is desirable for agencies
to deal with complaints about their actions and service, in the first instance.
This means that we must have confidence that agencies deal with complaints
appropriately. This review was initiated by my office to assess the
effectiveness of the internal complaints system of the Child Support Agency
(CSA), and was focussed narrowly on how the CSA Complaints Service
handled complaints referred by my office.
Methodology
This review was conducted in two parts. The first part addressed clients’
awareness of the Complaints Service and the strategies used by the CSA to
promote it. The second part, conducted as a joint project with the CSA,
assessed through case reviews the effectiveness of the Complaints Service in
dealing with complainants referred to it by my office, as an alternative to
investigation by my office.
Client awareness of the Complaints Service
In early 1997 my office undertook a brief survey of complainants to ascertain
their level of awareness of the CSA’s Complaints Service. The survey was
repeated during two further fortnights in 2000 as part of this review. During
the survey periods, Investigation Officers asked each person they spoke to
who had a current complaint about the CSA whether they were aware that the
CSA had a Complaints Service.

A brief analysis was also undertaken of the information available to the CSA
clients and the public about the Complaints Service — including the CSA’s
brochures and other publications, letters sent to clients, and the CSA’s
website — to ascertain what information was provided about the Complaints
Service and how accessible it was.
Case reviews
The project tracked a number of complainants to my office through their
dealings with the CSA Complaints Service to assess the effectiveness of
complaint handling. This included several complainants who complained
about the Complaints Service itself.

This aspect of the project was undertaken as a document review, through
examination of records in my office’s Complaint Management System (CMS)
and the CSA’s computer system and Complaints Service’s complaints
database.

Throughout this report, the main group of complaints (complaints from clients
about the CSA which my office declined to investigate and advised the person
to use the Complaints Service) are referred to as Group A or CSA
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complaints. The second group, where the complaint was about the
Complaints Service itself, are identified as Group B or Complaints Service
complaints.
Conclusions about client awareness
Very similar results were obtained from the Client Awareness Surveys in both
1997 and 2000. In 1997, 32% of the 193 respondents were aware of the
Complaints Service and 68% said they were not. There were 146
respondents in the four week period of the second survey in 2000, and of
these 34% were aware that the CSA had a Complaints Service and 66% were
not.

This second survey also identified whether the respondents were payers or
payees.

Just over half the respondents were payers with just less than half being
payees. Of the payers, 39% were aware of the Complaints Service compared
to 28% of payees.

The review of the CSA’s publications and other written material showed that
while the CSA does not routinely include reference to the Complaints Service
in its letters to clients, most publications do provide details about it. The
CSA’s website <www.csa.gov.au> does not have a readily identifiable section
about client rights, or an equivalent, which leads a user directly to information
about the Complaints Service.

This brief analysis suggests that additional methods of informing clients about
the Complaints Service may be required to improve client awareness.
Possible strategies to enhance awareness are detailed in our
recommendations.
Conclusions from the case review process
The review group assessed 52 complaints individually, awarding a score
against a set of criteria in four broad categories. Complaint handling in 43
cases was assessed as ‘excellent’, with 23 scoring a perfect score of 42. Four
cases were rated ‘satisfactory’ while five were rated as ‘needing
improvement’.

Of the 42 Group A complaints, 36 recorded a score of ‘excellent’ with 20
rating a perfect score. Three cases were ‘satisfactory’ and three were rated as
‘needing improvement’. For Group B, seven of the 10 complaints were rated
‘excellent’ with three perfect scores. One was considered ‘satisfactory’ and
two as ‘needing improvement’.

In a clear majority of cases, the Complaints Service effectively and efficiently
resolved the complaints originally brought to my office. It is therefore
reasonable for my office (in the absence of any special factors) to continue to
decline to investigate complaints where the complainant has not been to the
Complaints Service and to refer them there instead, with an invitation to
return to my office if the Complaints Service is unable to resolve the problem.
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Generally the ratings for Group A and Group B complaints were similar,
although it must be kept in mind that the sample for Group B was too small to
draw firm conclusions.

Areas of strength
The areas of strength identified (that is, areas where a score of excellent was
consistently achieved) were:
• Non-judgemental documenting of the matter (this was the only criterion
where every complaint was rated as ‘excellent’);
• Identification and documenting of issues on the CSA computer system;
• Appropriate investigative action;
• Appropriate negotiation with the Team Leader.

Areas needing improvement
The areas identified as needing improvement (that is, where lowest scores
were recorded) were:
• Internal recording procedures;
• Timeliness, the need to keep clients informed of progress, and
associated system documentation.

Some other specific results
• 79% of complaints were rated ‘excellent’ and a further 12% were rated
‘satisfactory’ against the criterion about being a ‘good example of
investigation and resolution’.
• 100% of Group A cases from NSW/ACT and Queensland were rated
‘excellent’ compared to 85% from South Australia/Northern Territory,
70% from Victoria/Tasmania and 50% from Western Australia. Although
the cases reviewed covered all CSA regions the sample per region is too
small to draw firm conclusions about regional performance.
• 58% of the complaints reviewed were from payees, although 80% of
complaints in Group B (five of the seven cases) were from payers.
• Overall, there was very little difference in the results for payers and
payees. 77% of payers’ complaints were rated as ‘excellent’ compared
to 86% for payees. For Group A, 85% of both payer and payee
complaints were rated ‘excellent’. For Group B payee complaints, only
20% achieved an ‘excellent’ rating, compared to 62% for payers.
• There was very little delay between the time my staff spoke to
complainants and advised them to call the Complaints Service, and
when the person did so. Nearly 70% of Group A complainants contacted
the Complaints Service on the same day that they spoke to my office. A
further 24% contacted the Complaints Service on the following working
day.
• This review did not assess what proportion of complainants who are
referred by my office to the Complaints Service do follow that advice. My
office’s Client Satisfaction survey conducted in 2000 (using 1999 data)
found that 92% of those CSA complainants who were referred back to
the Agency reported doing so; however, the survey did not specify the
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Complaints Service. Further research would be needed to establish
whether there is a significant number who do not contact the Complaints
Service. There may be a need for referral protocols with the CSA, to
ensure that complainants with problems do pursue their complaints
where my office declines to investigate.
• In Group B, the review determined that there was no justifiable reason
for the complaint about the Complaints Service in 72% of the cases; the
major problems identified with the complaint handling in these matters
were timeliness in following up matters and not keeping the client
advised of the progress of their complaint.

Factors contributing to the outcome
While the review was not aiming to identify what specific features of the
Complaints Service contribute to the high ratings, certain characteristics of its
structure and management emerge as relevant. These include the
commitment from management to an effective complaints handling process;
the centralised management of the Complaints Service which has developed
a professional, experienced and well-respected team with clear roles and
responsibilities identified for the Complaints Officers; a strong reporting
regime which leads to the ‘learnings’ from complaints being used to improve
service; and the strong role of training both for and by Complaints Officers.
Conclusion
This review has concluded that the CSA’s Complaints Service functions at a
high standard and provides a sound basis for my office to continue to decline
to investigate matters that the person has not attempted to resolve through
the Complaints Service. However the review has also highlighted a number of
areas for the CSA that would benefit from further attention. The
recommendations set out below are designed to address these areas.

Recommendations
Recommendation 1: That as part of ongoing monitoring and review of its
communications strategy, the CSA should incorporate strategies that
improve the awareness of the Complaints Service among CSA clients.
Consideration should be given to the feasibility and appropriateness of:
• Reviewing the design of the CSA website to provide more direct
access to information about the Complaints Service.
• Including a copy of the Complaints Service brochure with each
assessment notice.
• Incorporating information about the Complaints Service into all
correspondence.
• Incorporate into regular client satisfaction surveys, questions
about clients’ awareness of the Complaints Service.
• Providing further training, including the issuing of practice
directions, to ensure that all inquiry staff advise callers about the
Complaints Service as part of regular contact, and particularly
whenever an issue of concern or complaint is raised.
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• Ensuring information about the Complaints Service is included on
the CSA’s Interactive Voice Response system on its general
enquiry line (131 272).

Recommendation 2: That the Complaints Service ensure that its
ongoing training and quality assurance programs address the issues
identified by the review where improvement was warranted. Specifically,
these include:
• Communication with clients, with particular emphasis given to the
importance of keeping clients informed of the progress and
outcome of complaints;
• Timeliness of completing investigations;
• Recording of investigative action, remedies and follow–up action
on the CSA system and the Complaints Service database.
• Development of a system for the Complaint Team management to
monitor complaints so that incomplete or less than satisfactory
complaint handling can be addressed and followed up.

CSA Response
CSA has responded very positively to this review. Included below are CSA’s
comments in response to my recommendations.

Recommendation One - raising client awareness

CSA is in the process of redesigning a new page on our website
specifically dealing with client complaints. This will be integrated and
accessible from other key pages. In this way information about the
Complaints Service will be more overt and accessible to clients using
our website.

CSA is currently reviewing information included with assessment
notices. We will ensure that information about the Complaints Service
is considered as part of this review. At present, Complaints Service
information is contained in the Child Support Handbook which is
distributed with each new assessment notice.

All client correspondence currently provides an avenue for clients to
raise a complaint by referring them to their client service officer. This
effectively gives them access to step 1 of our complaints process. This
provides clients with adequate information about their options for
raising concerns without subverting the 3 step process.

In the next financial year, CSA will examine a new client research
model to improve the quality of the feedback we are receiving from our
clients. The new model will consider a number of 'point of service'
items of which Complaints may be included.

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Since the completion of your review, CSA has implemented a number
of strategies to provide client service officers with increased skills and
knowledge about client complaints. This includes an ongoing program
of information sessions run by complaints officers, a complaints module
delivered by complaints officers included in all Entry Level Programs
for staff, and enhanced feedback of learnings and emerging issues
through a range of Agency-wide communication channels.

As you are aware, the basis of the 3 step complaint process relies on
appropriate actioning of client concerns at the first point of contact.
This ensures that clients get relevant information at the most
appropriate point of their contact with the CSA. Including information
about the Complaints Service on the Interactive Voice Response
system may inadvertently encourage clients to contact the complaints
line directly, thereby skipping the first 2 steps of the process. This may
impact in two ways. Firstly, there are resource implications for CSA to
manage an increased number of step 3 complaints, and secondly, in
terms of client service, clients may be inconvenienced by being
referred back to step 1 of the process by a complaints officer.

I have complete confidence in the skills and abilities of the client
service officers on the general inquiry line to identify and escalate
complaints appropriately. They are supported in developing these skills
and making decisions via internal client service training, a coaching
system, and feedback provided by the Complaints Service.

Recommendation 2 - ongoing training and quality assurance
programs


Since the completion of your review, some of the initiatives outlined
above have been implemented to enhance the ongoing training and
quality assurance programs associated with the complaints service.

In addition, we are considering other options and models for ongoing
improvement, including the findings from your report. Your report will
be included as an agenda item at the next complaints conference. ...
This will provide an opportunity to reinforce your findings and to
workshop a number of the issues you have raised. These issues will
include communication with clients about the progress and outcome of
their complaint, timeliness, recording of investigative action, and
ongoing quality assurance and feedback of complaint handling. Also,
the impending introduction of a new IT system for CSA will improve the
management and monitoring system for the Complaints team.


I consider the above a reasonable response to my recommendations.


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2.
Purpose of the review

My office has adopted a policy of ‘decline and refer’ for agencies that have a
viable internal complaints service, on the basis that it is desirable for agencies
to deal with complaints about their actions and service, in the first instance.

My office therefore needs to be assured of the effectiveness of the CSA’s
Complaints Service so that when my officers exercise discretion not to
investigate and refer complainants to the Complaints Service, I can be
satisfied that they will receive a reasonable and appropriate service.

My office must also be satisfied that complainants do accept the advice to
pursue this avenue of redress and that there are no agency service factors
that may dissuade complainants from pursuing their concerns.

The review was designed to assess the effectiveness of the internal
complaints system of the CSA in dealing with matters that my office has
declined to investigate, including the level of client awareness of the
Complaints Service.

Although the CSA has a three-step complaints process (where complaints are
initially dealt with by enquiry officers, then Team Leaders, and then
Complaints Officers, as necessary) the case review element of the review
focussed only on matters dealt with by the Complaints Service as Step 3
complaints. The focus of the process was deliberately narrow with the aim of
assessing how effectively the Complaints Service handled only those
complaints that had had been referred by my office, and not how it conducted
all its business.



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3.
Background to the review

Towards the end of 1997, my office began planning a major project to review
the effectiveness of the internal complaints mechanisms of the three largest
complaint generating agencies — Centrelink, the Australian Taxation Office
(ATO) and the CSA. All of these agencies had recently established internal
complaint procedures. The CSA’s Complaints Service was established in July
1996, and the ATO’s Problem Resolution Service (PRS) and Centrelink’s
Customer Relations Unit (CRU) were established in mid–1997. A similar
structure was proposed for the review for each of these agencies,
commencing with the review of the ATO’s PRS.

In May 1997 the CSA had completed Phase One of an internal evaluation of
its Complaints Service. My office was represented on the evaluation Steering
Committee. In April 1998 the Australian National Audit Office (ANAO)
released a report of its enquiry into the Management of Selected Functions of
the Child Support Agency, which included a brief review of the CSA’s
Complaints Service, and made some recommendations for its improvement
(see section 4.6). The implementation of the recommendations from both
these reviews coincided with significant reorganisation across the CSA, from
July 1998 onwards. These resulted in considerable structural and
organisational change in the Complaints Service.

I wrote to the CSA in late 1998 advising that I would be undertaking a review
of the CSA Complaints Service, with the aim of assessing the Service against
good practice criteria, as well as examining my office’s referral procedures
and examining selected case studies. Work commenced on gathering
background information about the Complaints Service during 1999, but the
review was temporarily suspended pending the completion of the CSA’s
reorganisation. However, reviewing agency internal complaint handling
processes continued to be a priority for my office. I noted in the 1999–2000
Annual Report:
We need to have confidence that agencies deal with complaints
appropriately, as we decline to investigate many complaints we receive
on the basis that it is best for the agency to deal with the matter itself,
at least in the first instance.

As a consequence, we examine the complaint handling processes of
particular agencies from time to time to ensure that they have effective
arrangements in place.1

In late 1999, the changes were considered to be sufficiently bedded down for
a review by my office to be appropriate. Because of the internal evaluation in
1997 and the ANAO’s review in 1998, and the ‘learnings’ from the review of
the ATO’s PRS, it was determined that a simpler, more focused review should
be undertaken. It was decided that the review should primarily assess the

1 Commonwealth Ombudsman, Annual Report 1999-2000, Canberra, 2000. p 1.
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Document Outline

• 1
• 1. Executive Summary
  • Purpose of the Review
  • Methodology
    • Client awareness of the Complaints Service
    • Case reviews
  • Conclusions about client awareness
  • Conclusions from the case review process
    • • Areas of strength
      • Areas needing improvement
      • Some other specific results
  • Factors contributing to the outcome
  • Conclusion
  • Recommendations
  • CSA Response
• 2. Purpose of the review
• 3. Background to the review
• 4. Background to Complaints Service
  • 4.1 Introduction of Complaints Service
  • 4.2 The Three…Step complaints process
  • 4.3 Structure of the Complaints Service
  • 4.4 Current status of the Complaints Service
  • 4.5 Internal CSA evaluation of the Complaints Service
  • 4.6 ANAO review of CSA Complaints Service
  • 5. Methodology
  • 5.1 Client Awareness of Complaints Service
    • 5.1.1 Client awareness survey
    • 5.1.2 Review of CSA public information about the Complaints Service
  • 5.2 Case Reviews
    • 5.2.1 Approach
    • 5.2.2 Review Group
    • 5.2.3 Terminology
    • 5.2.4 Sample
      • Group A:
      • Group B
    • 5.2.5 Process
    • 5.2.6 Pilot
• 6. Conclusions about client awareness
  • 6.1 Conclusions from the Ombudsman Client Awareness Surveys
    • • • Date
  • 6.2 Conclusions from the review of CSA information
    • 6.2.1 Publications and other written material
    • 6.2.2 CSAs website
    • 6.2.3 Information through the Enquiry Line
  • 6.3 Strategies to enhance awareness
    • 6.3.1 Strategies identified in the ANAO report
    • 6.3.2 Further strategies
• 7. Conclusions from the case review process
  • 7.1 Conclusions from the cases reviewed
    • 7.1.1 General conclusions
      • • • • • Area*\Score
    • 7.1.2. Results from the Issues category
    • 7.1.3 Results from the Investigation category
    • 7.1.4 Results from the Remedy category
    • 7.1.5 Results from the Overall category
    • 7.1.6 Results of comparison by CSA region
      • • Group A
    • 7.1.7 Results of comparison of complaints from payers and payees
    • 7.1.8 Complaints made by the clients representative
    • 7.1.9 Time lapse from referral to Complaints Service and contact
    • 7.1.10 Whether clients take advice to contact Complaints Service
    • 7.1.11 Complaints about Complaints Service … Group B
  • 7.2 Areas of strength and areas needing improvement
    • • • • • • • Case study 4: Rita (payee)
• 8. Factors contributing to the high ratings for the CSAs Complaints Service
• 9. Conclusion
• *Criteria used in Case Reviews to assess complaint handling
• *Copy of Checklist
  • • • CSA Complaints Service Quality Assurance Program
    • Contact
    • Issues
    • Investigation
    • Remedy
    • Overall
• *Detail on selection of the case review sample

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